2 Case :-cv-000-mmd-cwh Document Filed 0/0/ Page of Howard Hughes Pkwy, Suite 00 Las Vegas, NV - 0 PARTIES. Plaintiff Future Motion is a Delaware corporation with a principal place of business located at Mission Street, Santa Cruz, California, 00.. Defendant Changzhou is a Chinese company with a principal place of business located at Longyu Western Road No., Wujin, Changzhou, China. JURISDICTION AND VENUE. This Court has federal question and diversity subject matter jurisdiction of this action. The court has federal question jurisdiction under U.S.C. and (a) because of the claim under U.S.C. for patent infringement. The Court has diversity jurisdiction under U.S.C. because Plaintiff Future Motion is a citizen of a State (California) and Defendant Changzhou is a citizen or subject of a foreign state (China), and because the amount in controversy, exclusive of interest and costs, exceeds seventy-five thousand dollars ($,000).. This Court has personal jurisdiction in this action because Changzhou conducts business, including attending trade shows, advertising, importing, selling and/or offering to sell products in connection with the allegations of this lawsuit, in the state of Nevada and in this judicial district.. Venue is proper in this district under U.S.C. and 00, because the injuries from the defendant s actions are felt in this district, and because Changzhou is subject to personal jurisdiction in this district. BACKGROUND FACTS. Plaintiff Future Motion created and sells the popular ONEWHEEL self-balancing electric vehicle.. Future Motion owns all right, title and interest in U.S. Pat. No. D, ( the patent ), titled SKATEBOARD, including the right to sue thereon and the right to recover for infringement thereof. The patent issued January, and will expire January, 0. A copy of the patent is attached hereto as Exhibit A. The patent gives Future Motion the right to exclude others from making, using, offering for sale, and selling the invention claimed in

3 Case :-cv-000-mmd-cwh Document Filed 0/0/ Page of Howard Hughes Pkwy, Suite 00 Las Vegas, NV - 0 the patent within the United States and from importing the invention claimed in the patent into the United States.. Future Motion also owns all right, title and interest in U.S. Pat. No.,0, ( the patent ), titled SELF-STABILIZING SKATEBOARD, including the right to sue thereon and the right to recover for infringement thereof. The patent issued August, and will expire April 0,. A copy of the patent is attached hereto as Exhibit B. The patent gives Future Motion the right to exclude others from making, using, offering for sale, and selling the invention claimed in the patent within the United States and from importing the invention claimed in the patent into the United States. 0. Defendant Changzhou is making, using, offering for sale, selling, and/or importing a self-balancing electric vehicle under the name Surfing Electric Scooter that appears to copy the ONEWHEEL design, constituting infringement of Future Motion s patent, as well as infringement of at least claims, and of Future Motion s patent. Publicly available materials advertising the Surfing Electric Scooter are attached hereto as Exhibit C.. Defendant Changzhou has announced its intention to exhibit and offer for sale the infringing Surfing Electric Scooter product at the International CES show to be held January - in Las Vegas, Nevada. Attached as Exhibit D hereto is a copy of an advertising flyer distributed by Changzhou in advance of the CES show. CLAIM INFRINGEMENT OF THE PATENT. Changzhou has infringed and is infringing the patent by making, using, selling, offering to sell and/or importing the Changzhou Surfing Electric Scooter.. Infringement by Changzhou has been and continues to be willful.. Future Motion has suffered, and will continue to suffer, substantial damages in an amount to be proven at trial, through lost profits, lost sales, and/or lost royalties, due to infringement by Changzhou.. Future Motion has suffered, and will continue to suffer, permanent and irreparable injury, for which Future Motion has no adequate remedy at law.

4 Case :-cv-000-mmd-cwh Document Filed 0/0/ Page of Howard Hughes Pkwy, Suite 00 Las Vegas, NV - 0. Future Motion is entitled to relief as provided by U.S.C.,,,, and. CLAIM INFRINGEMENT OF THE PATENT. Changzhou has infringed and is infringing the patent by making, using, selling, offering to sell and/or importing the Changzhou Surfing Electric Scooter.. Infringement by Changzhou has been and continues to be willful.. Future Motion has suffered, and will continue to suffer, substantial damages in an amount to be proven at trial, through lost profits, lost sales, and/or lost royalties, due to infringement by Changzhou.. Future Motion has suffered, and will continue to suffer, permanent and irreparable injury, for which Future Motion has no adequate remedy at law.. Future Motion is entitled to relief as provided by U.S.C.,,, and. PRAYER FOR RELIEF WHEREFORE, Future Motion prays for judgment as follows: A. That Changzhou has infringed, and is infringing, the patent and the patent in violation of U.S.C. ; B. That infringement by Changzhou is willful; C. That Changzhou be preliminarily and permanently enjoined against all acts of patent infringement, including but not limited to making, using, selling, offering to sell, and importing the Changzhou Surfing Electric Scooter; D. That Changzhou be required to deliver to Future Motion for destruction any and all articles in its possession and/or under its control that infringe the patent and/or the patent, including but not limited to all Changzhou Surfing Electric Scooters, and associated packaging and advertisements;

5 Case :-cv-000-mmd-cwh Document Filed 0/0/ Page of Howard Hughes Pkwy, Suite 00 Las Vegas, NV - 0 E. That Changzhou be ordered to pay Future Motion the damages that Future Motion has suffered due to patent infringement by Changzhou, together with interest thereon; F. That Changzhou be ordered to account for and pay Future Motion the total profits Changzhou has received from the sale of products infringing the patent and/or the patent; G. That this case be declared exceptional pursuant to U.S.C., due to willful infringement by Changzhou, and that Future Motion be awarded trebled damages and its reasonable attorneys fees and costs; and H. That Future Motion have such other and further relief as the Court and/or a jury deems just and proper. JURY DEMAND Future Motion hereby demands a trial by jury of all issues so triable. Dated this th day of January,. LEWIS ROCA ROTHGERBER CHRISTIE LLP, /s/ W. West Allen W. West Allen Nevada Bar No.: Howard Hughes Parkway, Suite 00 Las Vegas, Nevada Telephone: (0) -0 Facsimile: (0) - KOLISCH HARTWELL, P.C. SHAWN J. KOLITCH (Pro Hac Vice Pending) Oregon Bar No Pacific Building S.W. Yamhill Street Portland, Oregon Telephone: (0) - Facsimile: (0) - Attorneys for Plaintiff Future Motion, Inc.

Case 1:17-cv-00062-JCH-JHR Document 17 Filed 03/31/17 Page 1 of 9 LODESTAR ANSTALT, a Liechtenstein Corporation IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO Plaintiff, vs. Cause No.

Case 2:16-cv-01186-JRG-RSP Document 1 Filed 10/19/16 Page 1 of 8 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS SPIN MASTER, LTD., Plaintiff, v. HELLODISCOUNTSTORE.COM,

Lester Electrical Inc., IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEBRASKA Plaintiff, V. Diversified Power International, LLC and Nivel Parts & Manufacturing Co., LLC COMPLAINT Defendants.

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA ASHEVILLE DIVISION CIVIL ACTION NO.: 1:16-CV-165 EAGLES NEST OUTFITTERS, INC., Plaintiff DYLAN HEWLETT, D/B/A BEAR BUTT, Defendant.

Case 1:17-cv-06236 Document 1 Filed 08/17/17 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK THE GREEN PET SHOP ENTERPRISES, LLC, Plaintiff Case No.: 1:17-cv-6236

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE TELA INNOVATIONS, INC., v. Plaintiff, TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY, LIMITED and TSMC NORTH AMERICA, Defendants. C.A. No. JURY

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION POWERLINE INNOVATIONS, LLC, Plaintiff, v. (1) ELK PRODUCTS, INC.; (2) HOME AUTOMATION INC.; (3) HOMESEER TECHNOLOGIES,

Case 1:17-cv-11285-RGS Document 1 Filed 07/12/17 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS SPIDER SEARCH ANALYTICS LLC Plaintiff, v. CIVIL ACTION NO. TRIAL BY JURY

Case 1:12-cv-00666-UNA Document 1 Filed 05/29/12 Page 1 of 13 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE John R. Gammino, V. Plaintiff, Is American Telephone & Telegraph

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS MILLENIUM BIOLOGIX, LLC v. Plaintiff, BAXTER HEALTHCARE CORP. APATECH, INC., AND APATECH, LTD. Defendants. Civil Action No. 1:13-CV-3084

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA WESTERN DIVISION GREENOLOGY PRODUCTS, INC., a ) North Carolina corporation ) ) Plaintiff, ) ) v. ) CIVIL ACTION NO.: 16-CV-800

Case 5:07-cv-00156-DF-CMC Document 1-1 Filed 10/15/2007 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TEXARKANA DIVISION ESN, LLC, v. Plaintiff, CISCO SYSTEMS, INC.,

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE TELA INNOVATIONS, INC., v. Plaintiff, HTC CORPORATION and HTC AMERICA, INC., Defendants. C.A. No. JURY TRIAL DEMANDED COMPLAINT FOR PATENT

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI SOUTHERN DIVISION ECO ADVENTURE HOLDINGS, LLC and OZARK MOUNTAIN ZIPLINE, LLC, v. Plaintiffs, ADVENTURE ZIPLINES OF BRANSON LLC,

Case3:14-cv-04830-EDL Document1 Filed04/22/14 Page1 of 7 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE PRICEPLAY.COM, INC. v. Plaintiff, FACEBOOK INC., C.A. No. JURY TRIAL DEMANDED Defendant.

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS BEIJING CHOICE ELECTRONIC TECHNOLOGY CO., LTD., v. Plaintiff, CONTEC MEDICAL SYSTEMS USA INC. and CONTEC MEDICAL SYSTEMS CO., LTD.,

Case 1:16-cv-01019-TDS-JEP Document 1 Filed 08/01/16 Page 1 of 9 UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA VANESSA CHAVEZ, on behalf of herself and all others similarly situated

Case: 4:13-cv-01501 Doc. #: 1 Filed: 08/01/13 Page: 1 of 15 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MISSOURI VICTORY OUTREACH ) INTERNATIONAL CORPORATION ) a California

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS CARL ZEISS MEDITEC, INC. Plaintiff, v. OPTOVUE, INC. and MASSACHUSETTS INSTITUTE OF TECHNOLOGY, Defendants. Case No. JURY TRIAL REQUESTED

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action Number 13-cv-1404 MYELOTEC, INC. a Georgia Corporation, Plaintiff v BIOVISION TECHNOLOGIES, LLC a Colorado Corporation, Defendant

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION LakeSouth Holdings, LLC, Plaintiff, v. Ace Hardware Corporation, Defendant. Civil Action No. JURY TRIAL DEMANDED ORIGINAL

Case 2:16-cv-01455 Document 1 Filed 12/27/16 Page 1 of 9 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION NICHIA CORPORATION, Plaintiff, v. LOWE S HOME

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS FOREST LABORATORIES, INC., FOREST LABORATORIES HOLDINGS, LTD., MERZ PHARMA GMBH & CO. KGAA, and MERZ PHARMACEUTICALS GMBH, Plaintiffs,

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE GENETIC TECHNOLOGIES LIMITED, an Australian corporation, Plaintiff, v. LABORATORY CORPORATION OF AMERICA HOLDINGS, a Delaware corporation,

Case: 1:16-cv-11383 Document #: 1 Filed: 12/15/16 Page 1 of 15 PageID #:1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION CIVIL ACTION NO. WAL BRANDING AND MARKETING,

Case 1:16-cv-00886-UNA Document 1 Filed 09/30/16 Page 1 of 11 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE PFIZER INC. and UCB PHARMA GMBH, v. Plaintiffs, AUROBINDO PHARMA